PESP PACE Investment Tracker

Table of Contents

• Introduction
• Private Equity Risks
• Methodology
• PACE Tracker
• Case Study: InnovAge
• Private Equity, Opportunity Zones, and PACE
• Conclusion

Introduction

PACE – the Program of All-Inclusive Care for the Elderly – provides comprehensive medical and social services to certain older adults still living in the community.[1] Recent research has found private equity and venture capital investment in PACE organizations has surged in recent years.[2]

PACE has demonstrated promise as an integrated care model – research has linked it to fewer hospital visits,[3] shorter hospital stays and increased quality of life,[4] reduced family caregiver burden,[5] and lower costs.[6]

Recipients of PACE services must be 55 or older, live in an area serviced by a PACE program, and be eligible for a nursing home level of care.[7] According to the National PACE Association, the average PACE recipient is 76 years old, and has multiple complex medical conditions, cognitive and/or functional impairments, and significant health and long-term care needs – with approximately 90% dually eligible for Medicare and Medicaid.[8]

PACE operates as a unique three-way partnership between the federal government, state governments, and individual PACE organizations.[9] While federal law outlines core requirements – including covered services, service delivery rules, and participant protections[10] – each state has flexibility to design its own PACE program within those guidelines.[11] Differences in state approaches may contribute to regional disparities in PACE availability and investor interest. According to research by the National Academy for Health Policy (NASHP), the greatest barrier to access is geography. As of January 2022, 20 states had no PACE programs at all and no state offered full statewide access.[12] As of 2025, 17 states still have no PACE programs.[13]

In a recent study covering the six-year study period beginning in 2016, the number of private equity- and venture capital-backed PACE organizations grew from four to sixteen, representing a 300% increase.[14] The study found that by 2022, more than half of for-profit PACE organizations were owned by private equity and venture capital firms.[15]

Several factors may be making the PACE sector attractive to for-profit entities. According to NORC, for-profit PACE organizations are serving a younger and more diverse population, with a notable increase in Medicaid-only participants – changes that are likely due to “strategic targeting of underserved markets and states with more favorable policy environments, rather than deliberate strategies to diversify enrollee demographics.”[16]

As for-profit PACE organizations have grown in number, they have also seen rapid enrollment growth compared to non-profit and not-for-profit peers. One recent study in Health Affairs Scholar examined PACE program growth from 2010 to 2022, finding that after for-profits were allowed to enter the sector in 2016, program enrollment at for-profit PACE organizations grew 13.2%, compared to 5.7% growth at non-profit peers.[17]

PACE has demonstrated effective outcomes under non-profit ownership. But research has yet to show that for-profit providers achieve equivalent results. A 2017 review noted that while non-profit PACE programs were well-supported by evidence, comparisons of for-profit performance remained inconclusive.[18] The  Health Affairs Scholar 2025 study on PACE program growth stated: “Given emerging evidence that for-profit ownership in other health care sectors may reduce quality compared to nonprofits, policymakers should carefully monitor care quality and patient outcomes in PACE as for-profit entities increase.”[19]

This report provides a snapshot of private equity’s expanding footprint in the PACE sector and includes a nationwide ownership tracker compiled through federal ownership records, press releases, corporate filings, and other sources. Of 196 PACE programs, we identified 21 programs with private equity backing, one with venture capital backing, one backed by a venture capital/nonprofit JV, and seven with both PE and VC backing.

Private Equity Risks

Financial strategies endemic to the private equity business model raise particular risks for healthcare providers and patients, including PACE organizations.

Private equity firms often load companies with debt as part of their investment strategy. Debt-funded acquisitions, known as leveraged buyouts, allow firms to acquire companies using mostly borrowed funds – debt that is then placed on the acquired company’s balance sheet, and not the firm’s balance sheet. That debt can also be increased over time, especially to fund acquisitions or payouts to investors.

In 2024, private equity-backed companies comprised 21% of all healthcare bankruptcies, including 7 of the 8 largest cases by debt size.[20] The financial pressure created by high debt loads – combined with aggressive cost-cutting – can leave companies unable to respond to operational challenges or invest in safe, adequate care.

In healthcare, debt-driven strategies can have particularly harmful consequences. When companies prioritize meeting debt payments over patient care or staffing, the results can include understaffing, low wages, and reduced quality of care.

While research on venture capital (VC) ownership in healthcare remains limited, these investments differ from private equity in important ways. Unlike private equity firms, which typically use high levels of debt to finance acquisitions,[21] VC firms invest primarily through equity.[22]

This means that VC-backed healthcare providers are generally not burdened by debt-related obligations that can strain finances or lead to cost-cutting in patient care. However, there is a need for further research on how VC ownership models affect quality, sustainability, and oversight in long-term care programs like PACE.

Methodology

This analysis draws on manually compiled data including all known Program of All-Inclusive Care for the Elderly (PACE) organizations operating in the United States as of August 2025. PESP’s dataset includes details on ownership structure, private equity or venture capital involvement, and enrollment numbers.

The data was gathered through a multi-step process:

1. August 2025 Medicare Advantage (MA) / Part D Contract and Enrollment Data (MA Plan Directory) were downloaded from the Centers for Medicare and Medicaid Services (CMS) website and filtered for National PACE programs
2. Programs listed as “for-profit” in the tax status column in the CMS data were flagged for further investigation to determine whether they had financial backing from private equity or venture capital firms. These PACE organizations were initially researched using PitchBook,[23] a financial data platform that tracks private market transactions, to identify private equity or venture capital investors. Additional research and verification were conducted using company websites, press releases, news reports, and portfolio pages published by private equity or venture capital firms. At least 29 PACE programs have private equity and/or venture capital backing. See the summary of data section below for more information.
3. Online searches were also used to attempt to identify PACE programs operating under joint venture arrangements. One joint venture between a nonprofit and a VC firm was identified, and seven nonprofit joint ventures with no identified PE or VC funding were identified.
4. The PACE tracker includes various data directly from the CMS database, such as enrollment numbers. We also created three columns within the PACE tracker to reflect research on investor-backing.
   1. The column labelled “Type” indicates whether a for-profit PACE program has PE or VC backing, or both (PE/VC). Additionally, if the program is part of a joint venture with PE or VC backing, the nomenclature JV/PE or JV/VC is used. This column was only utilized for nonprofit PACE programs if they were involved in a JV.
   2. The column labeled “Investor(s)” names the relevant PE or VC firms involved.
   3. The column labeled “Notes” provides more detail for certain PACE programs that have investor-backing or are involved in JVs. This column also contains additional information for two nonprofit PACE programs that have business relationships with VC- or PE-backed healthcare businesses.
5. Enrollment figures reflect CMS data as of August 1, 2025. For the most current enrollment data, visit CMS.gov’s MA Plan Directory page.[24]

While CMS and National PACE Association data provided a strong foundation, ownership and financial relationships are not always clearly disclosed – particularly in the case of joint ventures, subsidiaries, or organizations with complex corporate structures. Some PACE programs may not yet appear – or may no longer appear – in federal data or association directories, including newer organizations and PACE entities that have ceased operating.

Additionally, the classification of private equity or venture capital involvement depends on publicly disclosed information, including press releases and firm websites. Some investor relationships may go unreported or change after the time of data collection. These limitations reflect broader challenges in transparency and oversight of private equity-owned care providers.

PACE Tracker and Summary of Data

As of August 2025, there are 196 PACE programs operating across 33 states and the District of Columbia. Our analysis found:

• 144 are nonprofit (73.5%) and 52 are for-profit (26.5%), as reported by CMS;
• A total of 71,210 individuals were enrolled in PACE programs as of July 2025.
  • Nonprofit programs enroll 53,975 individuals (76%)
  • For-profit programs enroll 17,235 individuals (24%)
• At least 30 PACE programs have private equity and/or venture capital backing, representing 15% of all programs. This figure consists of 21 programs with private equity backing, including three JVs, one with venture capital backing, one backed by a venture capital/nonprofit JV, and seven with both PE and VC backing.
• The average number of enrollees in nonprofit programs was 381 versus 361 for for-profit programs. The average number of enrollees in PE and/or VC-backed programs was 443.[25]
• There are 11,888 enrollees in PE and/or VC-backed PACE programs. This represents 68% of enrollees in for-profit PACE programs, and approximately 17% of all PACE enrollees.

The growing share of for-profit and investor-owned programs raises important questions about transparency, financial priorities, and long-term accountability in a model designed to serve medically complex older adults.

Case Study: InnovAge

InnovAge is the largest provider in the Program of All-Inclusive Care for the Elderly (PACE), serving approximately 7,740 participants across 20 centers in California, Colorado, Florida, New Mexico, Pennsylvania, and Virginia as of June 2025.[26]

The company was originally formed in 2007.[27] In May 2016, private equity firm Welsh, Carson, Anderson & Stowe (WCAS) acquired InnovAge for $196 million, converting it from a non-profit into a for-profit provider.[28] Four years later, in July 2020, WCAS partnered with Apax Partners in a joint ownership deal rumored to value InnovAge at $950 million.[29] As of mid-July 2025, InnovAge had a market capitalization of approximately $573.8 million.[30]

Following its March 2021 IPO, the company remained under the control of WCAS and Apax, which together currently own approximately 83% of InnovAge’s common stock. Due to the private equity firms’ majority control, InnovAge is classified as a “controlled company” under Nasdaq rules and is exempt from certain governance requirements, including independent board oversight.[31]

Political influence and transition to for-profit status

InnovAge’s transition to for-profit status was facilitated by Tom Scully, a former CMS administrator and operating partner at WCAS. Scully lobbied federal officials to revive a dormant rule that would allow for-profit entities to operate PACE programs, reversing a longstanding requirement that they be non-profit. At the same time, Scully worked with Colorado’s Attorney General to secure approval for the privatization of InnovAge, arranging the sale through a foundation to receive the proceeds.[32]

Scully joined InnovAge’s board following the acquisition, and appointed to the board former CMS Administrator Marilyn Tavenner, who had overseen the rule change enabling for-profit PACE participation.[33]

Under WCAS ownership, InnovAge expanded rapidly. By 2018, it had become the largest PACE provider in the U.S., operating in five states. According to a STAT News analysis from October 2022, InnovAge had more than doubled enrollment and tripled taxpayer-funded revenue since coming under private equity ownership. However, whistleblowers and health policy researchers argued the company prioritized financial growth at the expense of care. As enrollment surged, internal complaints about inadequate staffing and delayed medical services went unaddressed.[34]

Financial risks under private equity ownership

Private equity ownership also introduced financial risk to InnovAge’s operations.

In 2019 – three years after WCAS acquired the company – the private equity firm collected a $66.1 million dividend from InnovAge. That payout was funded not through surplus earnings, but through new debt that WCAS added to InnovAge’s balance sheet.[35] By June 2020, InnovAge’s long-term debt exceeded $215 million.[36]

InnovAge saw more modest debt levels as a publicly traded company. InnovAge reduced its long-term debt to $66 million by June 2024, partly due to restrictions in a 2021 Credit Agreement.[37] The company’s interest expense (i.e., interest payments on outstanding borrowings, plus interest income earned) also saw a decline – from a high of $16.8 million in FY2021 – but remained substantial, totaling over $4 million in FY2024.[38]

Despite decreased interest expenses in recent years, the company’s interest coverage ratio – a measure of whether earnings are sufficient to cover interest payments – has remained negative since 2021, meaning InnovAge was not generating sufficient profit to meet its interest obligations.

Table 1: Key financials for InnovAge for fiscal years 2020 through 2024

The company has acknowledged its growing costs and uncertain path to profitability, stating: “We may not succeed in increasing our revenue sufficiently to improve our profit margins. We finance our operations principally from revenue from our participant services and the incurrence of indebtedness.”[40]

The long-term consequences of  WCAS’s aggressive growth and reliance on debt became evident in InnovAge’s public financial disclosures following its 2021 IPO. Between fiscal years 2021 and 2025, InnovAge reported annual net losses in every year – ranging from $7.9 million to $44.7 million. These losses were accompanied by ongoing debt service costs. From 2020 to 2025, InnovAge’s annual interest expense ranged from $1.5 million to over $16.8 million. (See table above.)

These debt-related obligations persisted even as InnovAge remained under regulator-imposed enrollment freezes in major markets (discussed below), limiting its capacity to generate new revenue.  Although InnovAge reduced its long-term debt following its IPO, its continuing negative interest coverage ratios indicate that, even with lower debt obligations, the company has struggled to generate sufficient income to cover its interest payments – suggesting continued financial vulnerability amid ongoing operational and regulatory challenges.

In addition, InnovAge’s board of directors approved a share repurchase program in June 2024, authorizing the company to buy back up to $5 million of its common stock.[41] By March 2025, the company had repurchased more than 1.3 million shares at a cost of approximately $7 million after the board of directors approved the company buying back up to $2.5 million more of its common stock,  raising additional questions about the company’s financial priorities.[42]

InnovAge’s case illustrates a broader concern: in publicly funded care programs with fixed per-person reimbursement, extracting value through debt can compromise a provider’s ability to deliver quality care over time.   While the company eventually reduced its debt, portions of cash flow had to be directed toward servicing debt obligations that did not support clinical operations or workforce investment. InnovAge’s continued interest payments and negative net income suggests that these financial pressures may have had lingering effects.

Federal policy shifts may compound these pressures. In its most recent annual filing from September 2025, InnovAge warned that the One Big Beautiful Bill Act (OBBBA), adopted in July 2025, mandates significant reductions in federal Medicaid spending, along with new work requirements and increased eligibility verification requirements. InnovAge noted that these changes “may lead to decreased Medicaid enrollment among existing and prospective PACE participants, potentially reducing our funding and decreasing margins.”[43]

Investigations

InnovAge has been under scrutiny from federal and state regulators since 2021. A series of overlapping investigations and enforcement actions have raised concerns about the company’s ability to deliver safe and regulatory compliant care under private equity ownership.

• July 2021: InnovAge received a civil investigative demand (CID) from the Colorado Attorney General seeking information and documents related to Medicaid billing, patient services, and referral practices for its PACE program in Colorado.[44]
• February 2022: The U.S. Department of Justice (DOJ) issued a CID requesting information on audits, billing practices, and the quality and timeliness of patient care across five states: California, Colorado, New Mexico, Pennsylvania, and Virginia. In December 2022, InnovAge received a supplemental CID from the DOJ on the same matters.[45]
• October 2024: InnovAge received a third CID from the DOJ, requesting similar information but excluding Pennsylvania.[46]

Additionally, the state of California has imposed sanctions and expansion moratoria based on repeated findings of care deficiencies. An audit of InnovAge’s Inland Empire site found past due medical orders,[47] missed screenings,[48] improper denials of care,[49] and one participant who stopped taking medication and subsequently died, after the participant’s representative was not made aware of this change to the participant’s care plan.[50]

A 2024 audit of the company’s Sacramento site found deficiencies in eight areas including  inadequate recordkeeping,[51] delayed care,[52] and a failure to follow up on specialist recommendations.[53]

In response, DHCS froze InnovAge’s expansion in the state. As of early 2025, the Sacramento and San Bernardino centers remain under active review.[54] Due to unresolved concerns, the agency also revoked InnovAge’s attestations to open two planned new centers in Downey and Bakersfield.[55]

Pension fund lawsuit and settlement

In addition to investigations by state-level authorities, InnovAge has also received critical scrutiny from its own investors for allegedly misrepresenting its operational capacity and regulatory compliance in the lead-up to its 2021 IPO.

In July 2025, a federal court approved the announcement of a proposed $27 million settlement resolving a class action lawsuit against InnovAge Holding Corp, company executives, private equity owners WCAS and Apex, and others.[56] The case, brought by two public pension funds in Texas and one in Indiana, which were all investors in InnovAge, alleged that InnovAge and its executives made materially false and misleading statements in connection with the company’s March 2021 IPO.[57]

According to the complaint, InnovAge stated in its offering materials that it operated in compliance with all applicable regulations, and that the company’s business model enabled it to “consistently deliver high-quality care, achieve high participant satisfaction and retention, and attract new participants.”[58]

The pension fund plaintiffs argued that InnovAge’s singular focus on maximizing enrollment without sufficient staffing or specialist support led to severe workforce shortages, high caseloads, scheduling delays, lack of coordination, and insufficient training on the use of electronic medical records — resulting in substandard outcomes for participants. The plaintiffs also alleged that InnovAge executives had actually received reports and participated in calls with center directors and clinical staff who warned that the company’s rapid enrollment was overwhelming its ability to deliver care.[59]

The complaint alleged that, in response to these issues, InnovAge ordered its staff to “clean up” evidence of delays at its centers in advance of expected audits. It alleged one instance, in April 2021, where a director at one InnovAge center in Colorado instructed staff to delete a backlog of outstanding orders by deleting them from the facility’s medical records. The plaintiffs alleged multiple other instances where company leadership had repeatedly ordered staff to conceal evidence from auditors in California and Colorado, and to cancel orders for follow-up care that had not been met in over six months.[60]

By the time of the IPO in March 2021, the complaint alleged that InnovAge executives were aware that the company’s model had created a bottleneck of patients whose care needs were not being met, even as InnovAge continued to receive monthly payments for their enrollment.[61]

InnovAge denies any wrongdoing.[62] The proposed $27 million settlement will go to investors who purchased common stock between May 11, 2021 and December 22, 2021.[63]

Private Equity, Opportunity Zones, and PACE

Private equity firms have increasingly used Opportunity Zones (OZs) – a federal tax incentive program targeting low-income communities – to structure returns and gain tax advantages. According to a recent PESP report, private equity firms have raised over $16 billion through Qualified Opportunity Funds, which they use to purchase and develop property in Opportunity Zones.[64]

The purported benefits provided by opportunity zones are questionable. One major concern is that firms may utilize OZ financing for developments that were already entitled or underway – or even completed – effectively repurposing existing projects to access tax incentives without catalyzing new investment.[65] A study looking at 2018 and 2019 data found that OZs may produce “modest, if any, positive effects” on employment or poverty in designated communities – raising concerns about whether tax-incentivized private investment is delivering equitable outcomes.[66]

While most OZ investment has focused on real estate, the healthcare sector has begun attracting attention within this framework. In 2020, investment firm Nightingale Partners made an investment in PACE organization Edenbridge Health.[67]

Nightingale was founded by former CMS official John Gorman, and markets itself as a healthcare-focused Opportunity Zone fund investing in projects that address social determinants of health. Gorman has stated that the firm expects internal rates of return of at least 27–30% on its investments – returns that are furthered bolstered by the OZ program’s tax advantages.[68]

In July 2025, Congress passed the One Big Beautiful Bill Act, which made the Opportunity Zone program permanent while enacting the first major reforms since its creation. The law tightened eligibility criteria for zone designations, adds incentives for investments in rural areas, requires the U.S. Treasury to publish annual reports on OZ investments and outcomes including job creation, poverty reduction, and new business starts.[69]

Conclusion

As the Program of All-Inclusive Care for the Elderly (PACE) expands, new forms of ownership are beginning to enter a field historically led by nonprofit organizations. Private equity and venture capital firms are increasingly active in the space, signaling a shift in how PACE providers may be operated and financed.

The case of InnovAge underscores the need for closer oversight. Under private equity ownership, the company pursued rapid growth and complex financial strategies, including stock buybacks and debt-funded investor payouts, while facing multiple regulatory sanctions and investigations tied to care quality. Although more research is needed to understand whether these issues are widespread, InnovAge illustrates how financial incentives can, in some cases, overshadow operational needs.

Strong guardrails are needed before investor-driven models become more deeply embedded in PACE. Policymakers should prioritize financial transparency, limit extractive practices, and ensure that growth does not come at the expense of care. As the program evolves, oversight must evolve with it to protect both the stability of the model and the wellbeing of the people it serves.

Notably, some investor-backed PACE operators are partnering with hospital systems to expand into new markets. InnovAge, for example, operates a center in Northern California under a joint venture arrangement,[70] and has formed joint ventures with Tampa General Hospital and Orlando Health to co-brand its Florida centers. WelbeHealth has likewise collaborated with Sutter Health to launch two PACE programs in Northern California.[71]

BoldAge PACE and One Senior Care have also expressed interest in similar partnerships, which can help streamline required contracting and demonstrate local support for the operator to open new programs.[72] While these alliances may enhance care coordination across the continuum, they also raise questions about alignment between for-profit investor-backed companies and nonprofit hospitals in delivering consistent, affordable, patient-centered care.

Tax incentives such as Opportunity Zones can further complicate the landscape. Although it was designed to encourage investment in underserved communities, such programs are sometimes structured in ways that allow investors to extract financial value without guaranteeing improvements in services, workforce quality, or care access. In this context, investor interest may be drawn more to the financial upside of operating in designated tax-advantaged areas than to the needs of patients or the broader goals of PACE.

To protect the integrity of the program, policymakers and regulators must ensure that incentives intended to promote community-based care are not misused. Oversight efforts should be focused on preventing speculative or extractive financial practices and making sure that public funding supports providers who are committed to quality, transparency, and equitable service delivery.

Resources

[1] Centers for Medicare & Medicaid Services. “Program of All-Inclusive Care for the Elderly (PACE),” January 17, 2025. https://www.cms.gov/medicare/medicaid-coordination/about/pace.

[2] Private Equity Stakeholder Project PESP. “New Research on PE’s Expansion into PACE Programs,” April 21, 2025. https://pestakeholder.org/news/new-research-on-pes-expansion-into-pace-programs/, citing Dianne Munevar. “PACE Market Assessment: For-Profit Expansion.” NORC at the University of Chicago, March 2025. https://www.norc.org/research/projects/pace-market-assessment-for-profit-expansion.html.

[3] Segelman M, Szydlowski J, Kinosian B, McNabney M, Raziano DB, Eng C, van Reenen C, Temkin-Greener H. Hospitalizations in the Program of All-Inclusive Care for the Elderly. J Am Geriatr Soc. 2014 Feb;62(2):320-4. doi: 10.1111/jgs.12637. Epub 2014 Jan 13. PMID: 24417503.

[4] Williams, Carla T., and Soumya Chandrasekaran. “Program All Inclusive Care of the Elderly (PACE).” In StatPearls. StatPearls Publishing, 2025. http://www.ncbi.nlm.nih.gov/books/NBK597375/.

[5] Harold Urman. “PACE Enrollment Reduces Burden On Family Caregivers.” Vital Research. Accessed July 18, 2025. https://vitalresearch.com/insights/PACE-enrollment-reduces-burden-on-family-caregivers.html.

[6] CalPACE. “Fact Sheet: PACE Cost-Effectiveness.” March 4, 2021. https://calpace.org/wp-content/uploads/2017/12/PACE-Cost-Effective-Fact-Sheet-updated-3-04-21.pdf.

[7] Centers for Medicare & Medicaid Services. “PACE,” February 7, 2025. https://www.cms.gov/training-education/partner-outreach-resources/american-indian-alaska-native/ltss-ta-center/information/ltss-models/pace.

[8] National PACE Association. “Eligibility Requirements.” Accessed July 1, 2025. https://www.npaonline.org/eligibility-requirements.

[9] Centers for Medicare & Medicaid Services. “Programs of All-Inclusive Care for the Elderly (PACE) Manual.” Department of Health & Human Services, June 3, 2011. https://www.cms.gov/medicare/health-plans/pace/downloads/r1so.pdf, p. 1.

[10] 42 CFR Part 460 – Programs of All-Inclusive Care for the Elderly (PACE), Subpart F – PACE Services. Accessed August 20, 2025. https://www.ecfr.gov/current/title-42/part-460.

[11] National PACE Association. “Bringing PACE to Your State.” Accessed August 20, 2025. https://www.npaonline.org/starting-expanding-a-pace-program/resources-states/bringing-pace-to-your-state.

[12] Neva Kaye. “Five States’ Progress toward Expanding Access to PACE Services.” NASHP, May 3, 2022. https://nashp.org/five-states-progress-toward-expanding-access-to-pace-services/.

[13] See National PACE Association. “Find a PACE Program.” Accessed July 1, 2025. https://www.npaonline.org/find-a-pace-program. (“There are 188 PACE organizations operating in 33 states and the District of Columbia.”)

[14] Private Equity Stakeholder Project PESP. “New Research on PE’s Expansion into PACE Programs,” April 21, 2025. https://pestakeholder.org/news/new-research-on-pes-expansion-into-pace-programs/, citing Dianne Munevar. “PACE Market Assessment: For-Profit Expansion.” NORC at the University of Chicago, March 2025. https://www.norc.org/research/projects/pace-market-assessment-for-profit-expansion.html, PDF, p. 11.

[15] Private Equity Stakeholder Project PESP. “New Research on PE’s Expansion into PACE Programs,” April 21, 2025. https://pestakeholder.org/news/new-research-on-pes-expansion-into-pace-programs/, citing Dianne Munevar. “PACE Market Assessment: For-Profit Expansion.” NORC at the University of Chicago, March 2025. https://www.norc.org/research/projects/pace-market-assessment-for-profit-expansion.html, PDF, p. 5.

[16] Dianne Munevar. “PACE Market Assessment: For-Profit Expansion.” NORC at the University of Chicago, March 2025. https://www.norc.org/research/projects/pace-market-assessment-for-profit-expansion.html, PDF, p. 18.

[17] Katherine E M Miller, Ravi Gupta, and Daniel Polsky. “Growth of the Program of All-Inclusive Care for the Elderly and the Role of for-Profit Programs.” Health Affairs Scholar 3, no. 1 (January 16, 2025): qxae174. https://doi.org/10.1093/haschl/qxae174.

[18] Lori Gonzalez. “A Focus on the Program of All-Inclusive Care for the Elderly (PACE).” Journal of Aging & Social Policy 29, no. 5 (2017): 475–90. https://doi.org/10.1080/08959420.2017.1281092.

[19] Miller, Katherine E M, Ravi Gupta, and Daniel Polsky. “Growth of the Program of All-Inclusive Care for the Elderly and the Role of for-Profit Programs.” Health Affairs Scholar 3, no. 1 (2025): qxae174. https://doi.org/10.1093/haschl/qxae174.

[20] Valentina Dabos. “Private Equity Bankruptcy Tracker.” Private Equity Stakeholder Project PESP, February 12, 2025. https://pestakeholder.org/reports/private-equity-bankruptcy-tracker/.

[21] Kelly Knickerbocker. “What Is Private Equity and How Does It Work?” PitchBook, June 26, 2024. https://pitchbook.com/blog/what-is-private-equity.

[22] Kelly Knickerbocker. “What Is Venture Capital and How Does It Work?” PitchBook, September 3, 2024. https://pitchbook.com/blog/what-is-venture-capital.

[23] “Private Market Data and Financial Research Platform | Pitchbook.” https://pitchbook.com/.

[24] Centers for Medicare & Medicaid Services. “MA Plan Directory,” June 16, 2025. https://www.cms.gov/data-research/statistics-trends-and-reports/medicare-advantagepart-d-contract-and-enrollment-data/ma-plan-directory.

[25] For this calculation, we excluded programs that had less than ten (including zero) enrollees reported due to recent launch/lack of data in CMS.

[26] InnovAge Holding Corp. “10-K Annual Report, FY2025.” Securities and Exchange Commission, September 9, 2025. https://www.sec.gov/Archives/edgar/data/1834376/000183437625000062/innv-20250630.htm, p. 1.

[27] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 1.

[28] WCAS. “InnovAge | Investment Profile.” Accessed June 26, 2025. https://wcas.com/firm/investments/innovage/. InnovAge. “InnovAge Finalizes Investment Agreement with Welsh, Carson, Anderson & Stowe.” PR Newswire, May 16, 2016. https://www.prnewswire.com/news-releases/innovage-finalizes-investment-agreement-with-welsh-carson-anderson–stowe-300268797.html.

[29] Robert Holly. “Apax Partners Reportedly Acquiring Stake in WCAS’s InnovAge.” Home Health Care News, July 6, 2020. https://homehealthcarenews.com/2020/07/apax-partners-reportedly-acquiring-stake-in-wcass-innovage/.

[30] CNBC. “InnovAge Holding Corp (INNV).” Accessed July 18, 2025. https://www.cnbc.com/quotes/INNV.

[31] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 19.

[32] David Dayen. “Patient Zero.” The American Prospect, August 1, 2023. https://prospect.org/api/content/7a079260-2ff8-11ee-b4da-12163087a831/. Tara Bannow, Bob Herman. “Private Equity’s Welsh Carson, Casting Itself as a Noble Force, Relentlessly Pursues Profits in Health Care.” STAT, October 31, 2022. https://www.statnews.com/2022/10/31/welsh-carson-investment-strategy-innovage-caresource-emerus-usap/.

[33] Tara Bannow, Bob Herman. “Private Equity’s Welsh Carson, Casting Itself as a Noble Force, Relentlessly Pursues Profits in Health Care.” STAT, October 31, 2022. https://www.statnews.com/2022/10/31/welsh-carson-investment-strategy-innovage-caresource-emerus-usap/. David Dayen. “Patient Zero.” The American Prospect, August 1, 2023. https://prospect.org/api/content/7a079260-2ff8-11ee-b4da-12163087a831/.

[34] Tara Bannow, Bob Herman. “Private Equity’s Welsh Carson, Casting Itself as a Noble Force, Relentlessly Pursues Profits in Health Care.” STAT, October 31, 2022. https://www.statnews.com/2022/10/31/welsh-carson-investment-strategy-innovage-caresource-emerus-usap/.

[35] Eileen O’Grady, “Failures at PE-Owned Programs for Low-Income Seniors Raise Red Flags,” Private Equity Stakeholder Project, February 14, 2022. https://pestakeholder.org/news/failures-at-pe-owned-programs-for-low-income-seniors-raise-red-flags/ ; InnovAge Holding Corp. “S-1 Registration Statement.” Securities and Exchange Commission, February 24, 2021. https://www.sec.gov/Archives/edgar/data/1834376/000110465921027152/tm2037889-7_s1a.htm . Pg. F-52.

[36] InnovAge Holding Corp. “10-K Annual Report, FY2021.” Securities and Exchange Commission, September 23, 2021. https://investor.innovage.com/node/6971/html, p. 103.

[37] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 85.

[38] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 55.

[39] PitchBook. “Profile – InnovAge Holding.” Accessed Sept 22, 2025. https://my.pitchbook.com/profile/159097-87/company/financials/RATIOS. (“This ratio represents the value of a company’s earnings before interest and taxes (EBIT) relative to its interest expenses. This can be used to measure the number of times a company’s EBIT covers its interest expenses. This is calculated using EBIT divided by Interest Expense.”)

[40] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 55.

[41] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 49.

[42] InnovAge Holding Corp. “10-Q Quarterly Report, FY2025Q3.” Securities and Exchange Commission, May 6, 2025. https://investor.innovage.com/node/8711/html, p. 30.

[43] InnovAge Holding Corp. 10-K Annual Report, FY2025. Securities and Exchange Commission, 2025. https://investor.innovage.com/node/8906/html, p. 15.

[44] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 24.

[45] InnovAge Holding Corp. “10-K Annual Report, FY2024.” Securities and Exchange Commission, September 10, 2024. https://investor.innovage.com/node/8426/html, p. 24.

[46] InnovAge Holding Corp. “10-Q Quarterly Report, FY2025Q3.” Securities and Exchange Commission, May 6, 2025. https://investor.innovage.com/node/8711/html, p. 21.

[47] Department of Health Care Services. “Report on the Focused Medical Review of Total Longterm Care, Inc. DBA InnovAge Greater California PACE Inland Empire Fiscal Year 23-24.” December 19, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Focused-Medical-Review-Report-April2025.pdf, p. 13.

[48] Department of Health Care Services. “Report on the Focused Medical Review of Total Longterm Care, Inc. DBA InnovAge Greater California PACE Inland Empire Fiscal Year 23-24.” December 19, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Focused-Medical-Review-Report-April2025.pdf, p. 17.

[49] Department of Health Care Services. “Report on the Focused Medical Review of Total Longterm Care, Inc. DBA InnovAge Greater California PACE Inland Empire Fiscal Year 23-24.” December 19, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Focused-Medical-Review-Report-April2025.pdf, p. 27.

[50] Department of Health Care Services. “Report on the Focused Medical Review of Total Longterm Care, Inc. DBA InnovAge Greater California PACE Inland Empire Fiscal Year 23-24.” December 19, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Focused-Medical-Review-Report-April2025.pdf, p. 27.

[51] Department of Health Care Services. “Corrective Action Pan to Address InnovAge Sacramento PACE’s Non-Compliance.” February 1, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Sacramento-2024-Audit.pdf.

[52] Department of Health Care Services. “Corrective Action Pan to Address InnovAge Sacramento PACE’s Non-Compliance.” February 1, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Sacramento-2024-Audit.pdf, p. 6 of PDF.

[53] Department of Health Care Services. “Corrective Action Pan to Address InnovAge Sacramento PACE’s Non-Compliance.” February 1, 2024. https://www.dhcs.ca.gov/services/ltc/Documents/InnovAge-Sacramento-2024-Audit.pdf, p. 10 of PDF.

[54] InnovAge Holding Corp. “10-Q Quarterly Report, FY2025Q3.” Securities and Exchange Commission, May 6, 2025. https://investor.innovage.com/node/8711/html, p. 33.

[55] InnovAge Holding Corp. “10-Q Quarterly Report, FY2025Q3.” Securities and Exchange Commission, May 6, 2025. https://investor.innovage.com/node/8711/html, p. 33.

[56] Cohen Milstein Sellers & Toll PLLC. “Cohen Milstein Sellers & Toll PLLC Announces Proposed Class Action Settlement on Behalf of Purchasers of InnovAge Holding Corp. Publicly Traded Common Stock – INNV.” GlobeNewswire News Room, July 21, 2025. https://www.globenewswire.com/news-release/2025/07/21/3118778/0/en/Cohen-Milstein-Sellers-Toll-PLLC-Announces-Proposed-Class-Action-Settlement-on-Behalf-of-Purchasers-of-InnovAge-Holding-Corp-Publicly-Traded-Common-Stock-INNV.html.

[57] El Paso Firemen & Policemen’s Pension Fund, San Antonio Fire & Police Pension Fund, and Indiana Public Retirement System. “Second Amended Class Action Complaint for Violations of the Federal Securities Laws.” U.S. District Court, Colorado, September 17, 2024. https://www.cohenmilstein.com/wp-content/uploads/2022/06/Innovage-2nd-Amended-Complaint-09172024.pdf, p. 7 of PDF.

[58] El Paso Firemen & Policemen’s Pension Fund, San Antonio Fire & Police Pension Fund, and Indiana Public Retirement System. “Second Amended Class Action Complaint for Violations of the Federal Securities Laws.” U.S. District Court, Colorado, September 17, 2024. https://www.cohenmilstein.com/wp-content/uploads/2022/06/Innovage-2nd-Amended-Complaint-09172024.pdf, p. 11 of PDF.

[59] El Paso Firemen & Policemen’s Pension Fund, San Antonio Fire & Police Pension Fund, and Indiana Public Retirement System. “Second Amended Class Action Complaint for Violations of the Federal Securities Laws.” U.S. District Court, Colorado, September 17, 2024. https://www.cohenmilstein.com/wp-content/uploads/2022/06/Innovage-2nd-Amended-Complaint-09172024.pdf, p. 11 of PDF.

[60] El Paso Firemen & Policemen’s Pension Fund, San Antonio Fire & Police Pension Fund, and Indiana Public Retirement System. “Second Amended Class Action Complaint for Violations of the Federal Securities Laws.” U.S. District Court, Colorado, September 17, 2024. https://www.cohenmilstein.com/wp-content/uploads/2022/06/Innovage-2nd-Amended-Complaint-09172024.pdf, p. 81-82 of PDF.

[61] El Paso Firemen & Policemen’s Pension Fund, San Antonio Fire & Police Pension Fund, and Indiana Public Retirement System. “Second Amended Class Action Complaint for Violations of the Federal Securities Laws.” U.S. District Court, Colorado, September 17, 2024. https://www.cohenmilstein.com/wp-content/uploads/2022/06/Innovage-2nd-Amended-Complaint-09172024.pdf, p. 11 of PDF.

[62] Judge William J. Martinez. “Order Preliminarily Approving Settlement and Authorizing Dissemination of Notice of Settlement.” U.S. District Court, Colorado, June 17, 2025. https://www.cohenmilstein.com/wp-content/uploads/2022/06/Order-Innovage-Prelim-Approval-of-Settlement-June-17-2025.pdf, p. 16 of PDF.

[63] Cohen Milstein Sellers & Toll PLLC. “Cohen Milstein Sellers & Toll PLLC Announces Proposed Class Action Settlement on Behalf of Purchasers of InnovAge Holding Corp. Publicly Traded Common Stock – INNV.” GlobeNewswire News Room, July 21, 2025. https://www.globenewswire.com/news-release/2025/07/21/3118778/0/en/Cohen-Milstein-Sellers-Toll-PLLC-Announces-Proposed-Class-Action-Settlement-on-Behalf-of-Purchasers-of-InnovAge-Holding-Corp-Publicly-Traded-Common-Stock-INNV.html.

[64] Private Equity Stakeholder Project PESP. “Golden Opportunity: How Private Equity Profits from the Federal Opportunity Zone Tax Incentive.” June 4, 2025. https://pestakeholder.org/reports/golden-opportunity-how-private-equity-profits-from-the-federal-opportunity-zone-tax-incentive/.

[65] Private Equity Stakeholder Project PESP. “Golden Opportunity: How Private Equity Profits from the Federal Opportunity Zone Tax Incentive.” June 4, 2025. https://pestakeholder.org/reports/golden-opportunity-how-private-equity-profits-from-the-federal-opportunity-zone-tax-incentive/.

[66] Matthew Freedman, Shantanu Khanna, and David Neumark. “The Impacts of Opportunity Zones on Zone Residents.” National Bureau of Economic Research, March 2021. https://www.nber.org/system/files/working_papers/w28573/revisions/w28573.rev0.pdf.

[67] Nightingale Partners LLC. “Nightingale Partners Invests in Edenbridge Health to Offer Innovative Eldercare Options to Underserved Seniors.” PR Newswire, October 28, 2020. https://www.prnewswire.com/news-releases/nightingale-partners-invests-in-edenbridge-health-to-offer-innovative-eldercare-options-to-underserved-seniors-301160959.html.

[68] Darwin Research. “Podcast 122: Investing in Social Determinants of Health with John Gorman.” Darwin Research Group, October 30, 2020. https://www.darwinresearch.com/122/.

[69] David Wessel. “How Did the One Big Beautiful Bill Act Change Opportunity Zones?” Brookings, July 8, 2025. https://www.brookings.edu/articles/how-did-the-one-big-beautiful-bill-act-change-opportunity-zones/.

[70] InnovAge Holding Corp. 10-K Annual Report, FY2025. Securities and Exchange Commission, 2025. https://investor.innovage.com/node/8906/html, p. 10.

[71] Diane Eastabrook. “Why PACE Providers Are Forging Stronger Ties with Health Systems.” Modern Healthcare. August 28, 2025. http://www.modernhealthcare.com/post-acute-care/mh-pace-partnerships-tampa-general-orlando-health/.

[72] Diane Eastabrook. “Why PACE Providers Are Forging Stronger Ties with Health Systems.” Modern Healthcare. August 28, 2025. http://www.modernhealthcare.com/post-acute-care/mh-pace-partnerships-tampa-general-orlando-health/.